1. Reporting of Over Pressurization Events
Restoring Trust in Pipeline Safety
Nov 2nd & 3rd, 2006
New Orleans, LA
Accufacts Inc.

2. Over Pressurization Today’s Focus on Transmission Pipelines
Allowed “Accumulation” over MOP/MAOP
MOP = Maximum Operating Pressure (liquid)
MAOP = Max Allowable Operating Pressure (gas)
For Sound Pipeline/Welds Not a Problem
High SMYS Tolerance
Large Safety Factor on Properly Tested/Inspected Systems
Exceeding Regulatory/Code Pressure Accumulation Limit
Suggests Serious Loss of Operator Control of Pipeline
Calls into Question Management Processes
Accufacts Inc.

3. Over Pressurization The Belief - Canvass the Operators The Reality
No one “Exceeds” Accumulation Limit
A Serious Regulatory/Code Violation
The Reality
Many Forces Increase Risk of Over Pressure
Seeing too Often
No Real Defense for this Violation
Loopholes in Regulatory Reporting
Biases the Database
Misstates Pipeline Failure Mode Distribution
Taints IM & Risk Approaches
Accufacts Inc.

4. Over Pressurization Current Regulations Drivers of Overpressure Events
Allow Avoiding Reporting to PHMSA
Past Argument Burden of Reporting
No Failure What’s the Concern?
“Loose” Requirement for Certain Pressure Records
How Can One Have an Effective IM Program?
Drivers of Overpressure Events
Very Poor Management Practices
Serious System Breakdowns - No Accident
Cost Reduction and Efficiency Forces
Over Reliance on Electronics as Fail Safes
Changing Role of Transmission Pipelines
Accufacts Inc.

5. Over Pressurization Regulatory Recommendations Outcomes
Eliminate Reporting Waivers in Pipeline Regulations
191.23(b)(4) - gas, (b)(3) - liquid
Mandate Simple Electronic Reporting within 24 hours (all events in Excess of Permitted Accumulation Pressure)
Strengthen System Pressure History Recordkeeping
Outcomes
Public Confidence and Creditability in Database
Strengthens Certain Risk Approaches for Pipelines
Protects the Pipeline Operator and the Public
All Parties Have Same Objective - Keep the Pressure Within the Pipe
Accufacts Inc.